The complaint, filed at the U.S. District Court in Santa Ana, Calif., says Henry Nicholas and Henry Samueli purposefully backdated stock options, the Los Angeles Times reported.

The complaint alleges former Chief Financial Officer William J. Ruehle and Broadcom General Counsel David Dull participated in the scheme, the Times reported.

Broadcom settled a similar suit filed April 22 for $12 million. That case involved as many as 88 instances of options grants backdating between June 1998 and May 2003, the Times reported.